https://www.taxtmi.com/caselaws?id=59329 Consideration for supply of technical documentation and know-how under a collaboration agreement was treated as royalty under Article 12 of the India-Russia DTAA because the non-resident retained property in the technical drawings, designs and know-how. The licensee received only a non-exclusive, purpose-limited right to use the materials, could not assign the rights, and was bound by confidentiality obligations. As the arrangement was not an outright sale but permission to use retained technical property, the payment fell within royalty rather than sale proceeds. en-us Wed, 29 Sep 2004 00:00:00 +0530 Tue, 28 Dec 2010 18:29:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59329 Consideration for supply of technical documentation and know-how under a collaboration agreement was treated as royalty under Article 12 of the India-Russia DTAA because the non-resident retained property in the technical drawings, designs and know-how. The licensee received only a non-exclusive, purpose-limited right to use the materials, could not assign the rights, and was bound by confidentiality obligations. As the arrangement was not an outright sale but permission to use retained technical property, the payment fell within royalty rather than sale proceeds. Case-Laws Income Tax Wed, 29 Sep 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59329